NUREG-0588, Responds to 870709 Request for NRR Assistance in Determining Adequacy of Two Test Repts Re Acceptance Criteria of NUREG-0588,Category I.Qualification of Kulka Terminal Blocks Demonstrated & Not Used in Instrumentation Circuits

Responds to 870709 Request for NRR Assistance in Determining Adequacy of Two Test Repts Re Acceptance Criteria of NUREG-0588,Category I.Qualification of Kulka Terminal Blocks Demonstrated & Not Used in Instrumentation Circuits

ML20237B043
Person / Time
Site:	Callaway
Issue date:	12/09/1987
From:	Holahan G Office of Nuclear Reactor Regulation
To:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
RTR-NUREG-0588, RTR-NUREG-588 NUDOCS 8712150426
Download: ML20237B043 (2)

Text

1 i-December 9, 1987 MEMORANDUM FOR: Hubert J. Miller, Acting Director Division of Reactor Safety. Region III i FROM: Gary M. Holahan, Assistant Director for Regions III and V Division of Reactor Projects - III IV, V and Special Projects Office of huclear Reactor Regulation j

SUBJECT:

ENVIRONMENTAL QUALIFICATION (EQ) 0F KULKA TERMINAL BLOCKS AT CALLAWAY (TIA III-87-8)

This memorandum is in response to your July 9, 1987 request for NRR assistance in determining the adequacy of two test reports (Bunker Ramo ]

Peport #123-2222 and Conax Report #1PS675) in regard to the acceptance l

criteria of NUREG-0588, Category I. Based on our review, it is concluded that qualification of KULKA terminal blocks at Callaway has been demon- l l

I strated and that this conclusion is, ir part, based on our understanding that these terminal blecks are not used in instrumentation circuits.

A detailed evaluation in enclosed.

l 02CCit GW:5tt 1

Gary M. Holahan, Assistant Director for Regions III and V Division of Reactor Projects - III IV, V and Special Projects Office of Nuclear Reactor Regulation i

Enclosure:

As stated DISTRIBUTION:

Docket files; NRC PDR 4 Local POR PDIII-3 r/f KPerkins GHolahan TAlexion PKreutzer DCrutchfield HWalker, PSB

{ l Office: LA/PDIII-3 1 PD/P 3 A P Surname: PKredtzer TAlW6ii/bl KPe n GHolahan Date: 12/7 /87 12/4_/87 12/ /87 12/}/87 8712150426 871209 PDR P ADOCK 050004B3 pop L_____________________---------_____________________.______.________ _ _ - . - - - - - - . -- - - - - - - - _ _ _ _ _ _ - - _ _ _______.-___________________o

)

I NRR EVALUATION OF KULKA TERMINAL BLOCKS AT CALLAWAY PLANT As a result of an E0 inspection at the Callaway Plant conducted by Region i III, it appeared that the licensee's documentation file did not clearly I demonstrate qualification of KULKA terminal blocks. Therefore, NRR was i requested to review the two test reports to determine compliance with NUREG-0588 guidance. As indicated in Region III's letter, the Bunker -

Ramo test report (#123-2222) does have some discrepancies, most notably in the removal of the terminal blocks from their voltage source for 57 hours6.597222e-4 days <br />0.0158 hours <br />9.424603e-5 weeks <br />2.16885e-5 months <br /> following only 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> of testing. We have also noted that the primary component being qualified by the testing documented in this report is an electrical penetration assembly which included the terminal blocks as sub-components. Although this may not be a discrepancy, it l has influenced our decision to choose the Conax report #1PS675 as the primary document to demonstrate qualification of these terminal blocks.

In the Conax report, terminal blocks are the primary components being tested. Region III has also indicated and we have recognized that this report (1PS675) demonstrates successful testing of unaged KULKA blocks.

This testing does not comply with the guidance of NUREG-0588 Category I.

However, it has been reported by Sandia National Laboratories (NUREG/CR-3691) and acknowledged by the staff (Inspection and Enforcement Information Notice IN 84-47), that neither the accelerated aging process nor seismic testing will significantly affect terminal block performance. In addition, by letter dated June 29, 1987 (Donald F. Schnell, Vice President to W. L.

Forney, Chief, Reactor Project Branch 1, Region III) the licensee provided a failure modes and effects analysis for 480V applications at the Callaway Plant, which addressed two anomalies identified in the Conax test report (i.e., the failure of two 250 milliamp fuses, one at 150.7 hour8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and one at 198.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> into the test). As a result of the analysis, the licensee concluded that the equipment would have performed its post-accident func-tion well before the time of the test anomalies. This type of analysis is acceptable in accordance with NUREG-0588 and Revision 1 of Regulatory Guide 1.89. Since this analysis was limited to 480V applications, use at lower voltages must be evaluated on a case-by-case basis. With the above limitation, we believe that the Sandia Peport provides sufficient justifi-cation to conclude that a successful qualification test of these terminal blocks without preaging is acceptable, although the guidance in NUREG-0588 Category I has not been completely satisfied. The staff's acceptance is, .

in part, based on our understanding that these terminal blocks are not used in instrumentation circuits, thereby eliminating our concerns in this area.

Based on our review of the documentation provided (i.e., the Bunker Ramo test report and the Conax test report) and our review of IE Information Notice 84-47 and the statement in NUREG/CR-3691, it is concluded that qualification of KULKA terminal blocks has been demonstrated and that this conclusion precludes the use of these blocks in instrumentation applica-tions. It is further concluded that in this instance, sufficient information is available to justify the use of the Conax test report to demonstrate qualification even though the specific guidance for preaging has not been satisfied as outlined in NUREG-0588 Category I.

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